Marker’s table processor garbled the multi-column tables in
2026-08-17-icc-carbon-accounting-landscape-review.md (Tables 1, 2, 3, 4 came
out with columns collapsed or dropped). The text below was extracted directly
from the PDF with pdfplumber (uv run --with pdfplumber) and re-tabulated by
hand. Page numbers refer to the printed PDF pages.
Update 2026-08-17: the Markdown twin was subsequently replaced with a conversion produced locally by Martin Pompéry. That version does carry Table 1 with its columns intact (the one table my own run dropped entirely); its body text is otherwise identical. Tables 1b, 2, 3 and 4 remain collapsed there as well, so this file stays in use for those.
Source of record remains
sources/whitepapers/2026-08-17-icc-carbon-accounting-landscape-review.pdf;
this file is a faithful transcription aid, not a new source.
Table 1. Functional clusters of the carbon-data ecosystem (p. 13)
Nine functional clusters. (Marker dropped this table entirely.)
| Cluster | Role | Principal strengths | Principal limitations |
|---|---|---|---|
| Data providers (primary data) | Provide actual data when practical and applicable, with a clear hierarchy that prefers measured site-specific data. | High accuracy, granularity, and decision-usefulness; essential for product differentiation, benchmarking, and credible embedded-emissions comparisons. | Limited coverage and high collection cost. Data may be difficult to verify, standardise, and share across value chains. |
| Data providers (secondary data) | Fill gaps with emission factors and industry averages where primary data are unavailable; high-quality secondary data can complement primary data. | Enabling scalability when primary data cannot be obtained. | Low granularity and accuracy; risk of systematic under- or overstatement relative to actual operations. |
| Voluntary carbon-credit systems | Convert reductions or removals beyond the value chain into tradable instruments. | Mobilising capital and enabling market mechanisms. | Detached from physical product flows. Risk of double counting and integrity concerns. |
| Accounting standards and frameworks | Define the rules by which carbon data are quantified and structured. | Establish global comparability and credibility; the foundation of the system. | Mostly non-digital and non-transactional. Do not by themselves ensure real-world data quality or traceability. |
| Systems (ERP, platforms, infrastructure) | Capture, exchange, and process carbon data across value chains at the scale of business and trade. | Operational backbone. Enabling integration across supply chains. | Often not standardised, not interoperable, and not audit-grade. |
| Verification, audit and assurance | Independently check that reported carbon data are accurate and complete. Provide validation and verification at limited or reasonable assurance by accredited third parties. | Confer credibility and decision-grade trust. Increasingly mandated by regulation (CBAM, LCFS, EU ETS). | Constrained by the quality and traceability of the underlying data and methods. Assurance levels and accreditation vary, and self-verification is still permitted in places. |
| Disclosure initiatives and certifications | Make carbon data visible and auditable. Translate accounting into reporting rules and labels. | Driving transparency, benchmarking, and responding to stakeholder preferences. | Aggregated, static, and periodic. Not consistently standardised, interoperable, and audit-grade; not designed for real-time or product-level tracking. |
| Corporate target-setting (voluntary) | Set ambition and define reduction pathways. | Align corporate strategy with climate goals. | Not operational. Depends on data from other sources that may have limitations. |
| Policy and regulation | Leverage competitive market forces through compliance obligations — monitoring, reporting, verification, pricing — with legal force. | Forcing adoption and standardisation within jurisdictions. | Often built on proxy data and averages. Can lag operational data systems. Fragmentation among jurisdictions. |
Source line: “Landscape analysis by the Secretariat of the Technical Expert Panel on Carbon Accounting.”
Table 1b. Counting and reporting compared to carbon accounting (p. 14)
Marker preserved only fragments of the left column.
| Dimension | Carbon counting and reporting | Carbon accounting |
|---|---|---|
| Data collection | Ongoing collection with periodic consolidation, typically mixing primary and secondary data sources. | Transaction-based recording (at each exchange), resting on data recorded at source, enabling an easier increase of the share of primary data over time. |
| Time period | Mixes temporal layers (past, present, and projected periods), drawn from life-cycle models; results compiled for a study period and often reused across reporting cycles. | A specified period, aligned with transactions and financial records. |
| System boundary | Combines attributable direct and indirect emissions; may allow consequential assessment. | Attributable data within fixed boundaries (i.e., gate-to-gate). |
| Data quality | Potential for gaps, estimates, inconsistencies, and overlapping emissions data across reporters. | Completeness and consistency framed by carbon mass balance, a rulebook, and double-entry crosschecks. |
| Recording device | Single-entry inventory tabulation. | A dual-sided ledger with a structured chart of accounts and double-entry recording that allows data to flow along the value chain. |
| Reports generated | No widely adopted framework generates both entity-level and product-level reports that can be reconciled. | Generates fully aligned entity-level and product-level reports. |
“Adapted from EFI Foundation, Towards Harmonized Carbon Accounting (March 2026), Table 1.”
Table 2. Regulatory regimes coded on product-carbon dimensions (p. 18)
| Dimension | EU CBAM | California LCFS | China CFMS |
|---|---|---|---|
| Status and purpose | Mandatory; price carbon embedded in imports; prevent leakage. | Mandatory; credit/deficit market on fuel carbon intensity. | Emerging national PCF infrastructure; trade compatibility. |
| Level of assessment | Product (per imported good). | Product (per fuel pathway). | Product (per good). |
| How embedded emissions are calculated | Specific embedded emissions (tCO₂e/t) by standardised process, allocated to products following ETS-consistent process attribution rules, then reported per CN code. | Well-to-wheel life-cycle carbon intensity (gCO₂e/MJ) via the mandated CA-GREET4.0 model. | Life-cycle PCF per GB/T 24067-2024 (ISO 14067-based); national emission-factor database. |
| Sectoral / product coverage | Iron and steel, aluminium, cement, fertilisers (incl. ammonia), electricity, hydrogen; expanding towards additional ETS-relevant sectors over time. | Transportation fuels (gasoline, diesel, ethanol, RD, RNG, hydrogen, electricity, alt-jet). | Cross-sector; 100 key products by 2027, 200 by 2030; priority high-trade-exposure sectors. |
| System boundary | Gate-level direct emissions plus indirect emissions from electricity where applicable, and emissions attributed from certain precursor inputs as defined in the methodology. | Cradle-to-grave (well-to-wheel), including indirect land-use change. | Defined per study; often cradle-to-gate or broader life-cycle scopes. |
| Data basis | Verified primary preferred; punitive tightening defaults where unavailable. | Operating inputs to a fixed model; lookup secondary data / Tier 1: secondary defaults + limited primary inputs / Tier 2: high share of primary data (customised modelling). | Primary encouraged; national secondary database for gaps. |
| Verification | Third-party, accredited, reasonable assurance (definitive phase). | Mandatory initial validation + annual third-party verification. | Traceable, auditable data; assurance regime maturing. |
| Removals / biogenic | Removals not currently recognised; biogenic per RED criteria. | Net life-cycle treatment; biogenic accounted in pathway CI. | Per ISO 14067 life-cycle treatment. |
Table 3. Criteria mapped to regulatory demand (p. 24)
| Criterion | What it requires | Corresponding regulatory demand |
|---|---|---|
| A. Accuracy | Measured or science-grounded quantification; sound materiality. | CBAM and LCFS require scientifically grounded, installation- or pathway-level quantification, not unverified self-reported estimates — and compliance value attaches to figures that determine tariffs, credits, and penalties. |
| B. Verifiability | Audit trail; third-party reasonable assurance. | CBAM, LCFS, and EU ETS all require accredited third-party verification; China is building traceable, auditable data. |
| C. Comparability | Common units, periods, boundaries, allocation. | LCFS mandates a standardised model framework (CA-GREET); CBAM prescribes a harmonised methodology with CN-code-based reporting categories — to make competing products comparable. |
| D. Representational faithfulness | Physical mass/energy balance; unbiased, complete recording. | Regimes attach consequences to figures that must correspond to actual physical production — CBAM’s mass-based attribution and the LCFS’s substantiated pathway records are checks that reported accounts match reality. |
| E. Fungibility | Standardised units; primary-data hierarchy; tightening defaults. | CBAM penalises default values; LCFS requires substantiated operating data; all push towards verified primary data expressed in common units. |
| F. Conservation across entities | Count once; allocate fully; transfer with title. | CBAM attributes emissions to specific goods and avoids double pricing; the differentiation purpose fails if an emission is counted twice or lost. |
| G. Completeness of scope | Ensure total system emissions are fully accounted for across entities. | Regulatory systems require complete accounting within defined boundaries. Missing emissions reduce comparability, weaken integrity, and can affect compliance obligations, tariffs, or carbon prices. |
| H. Operability | System of record-ready; transaction-based; recursive. | CBAM quarterly/annual cycles and LCFS pathway reporting reward systems that produce data continuously, not annually by hand. |
Table 4. What each approach contributes, and what remains open (p. 32)
| Approach | What it contributes | What remains open (relative to the target architecture) |
|---|---|---|
| ISO 14067 | The international standardisation LCA backbone for PCFs; science-first quantification with a rigorous allocation hierarchy; underpins the Product Category Rule mechanisms through which sector-specific rules are made more comparable. | Designed as a quantification standard, not an inter-entity accounting system; flexibility is a design feature to serve multiple end-uses; sector rules must narrow optionality to mitigate the low comparability. |
| GHG Protocol Product Standard | A cross-sector LCA quantification method; reporting and disclosure provisions; currently being on an alignment path with ISO 14067 towards a joint product standard. | Inter-entity transfer of embedded emissions; low comparability across reporters given methodological latitude; not designed for transaction-level operability. |
| EU PEF | A working template for engineered comparability: prescriptive category rules, mandatory verification for claims, structured data-quality rating. | Transfer or transactional recording. |
| ISCC CFC | Certification-grade assurance practice: mandatory accredited audits, primary-data thresholds, operational mass-balance chain-of-custody experience. | Propagation of emissions data along the value chain. |
| PACT v3 | Working, data-exchange infrastructure; a fixed cradle-to-gate default boundary and common exchange format; the Primary Data Share metric and maturity pathway. | Exchanges data rather than accountable quantities; period-average static figures rather than transaction-level records; does not provide conservation, transfer, or reconciliation mechanisms; inherits the quantification latitude of its methodological basis. |
| E-Ledgers and related approaches | The transactional accounting architecture: emissions recorded once at source, allocated by causal logic, transferred with legal title, reconciled to product to entity, verified through audit-by-design. Primary data incentives. | Allocation and boundary rules to be fully specified; operability for system-of-record-ready ledger specifications; assurance protocols; testing and validation at scale. |
Footnote to the table: “Each approach succeeds in contribution against its own design intent; ‘open’ items describe distance from the ledger-based target architecture stated in the premise of this review.”